Stakeholder perceptions: 6 key findings

15 August 2017, Jo Prowse, Chief Executive

Many of you took part in a piece of stakeholder perceptions research we commissioned earlier this year – a big thank you for your time and feedback.

We commissioned this to gain an independent, objective view of perceptions of us, to identify areas where we could improve and benchmark our performance. I promised to give you some more detail about the findings and what we are planning to do in response. So here are the top 6 findings from the research:

Stakeholder feedback of us is more positive than negative and our performance regarded to be significantly improved. 60% of you have a favourable view of us a regulator and 68% saw us as effective. A number of you commented on a sense that we have improved significantly over the last 18-24 months, which was good to hear.

Our new mission and values were seen as appropriate and we are perceived to be delivering against most aspects of these. 74% of you associated us with the consumer protection aspect of our mission, whereas 58% associated us with encouraging competition, growth and innovation in the consumer interest.

We are perceived to be particularly strong on openness and stakeholder engagement, and to have improved in the fairness and proportionality of our decision-making. Stakeholders in both the quantitative and qualitative elements of the research mentioned that our style is open and collaborative and that we are seen as a responsive regulator – and that’s something I am particularly pleased about; as I’ve said on many occasions, I genuinely believe we can serve consumers better by working together. Our decision-making, linked to the introduction of Code 14, is also perceived to have improved.

Maintaining an appropriate balance between consumer protection and a healthy industry is seen to be a challenge. Most of you recognise the dual nature of our mission but acknowledge that this can be difficult. A number of you were supportive of robust enforcement to not only protect consumers but to also protect the reputation of the market.

Our speed of response was identified as an area for improvement as it can be seen to prevent us from acting decisively. Like all regulators we recognise the need to act in a timely manner and we are working on ways to do this better. For example, we now have a risk assessment process in place, which should enable us to quickly identify consumer risk and introduce regulatory measures where appropriate. On the other hand, formal regulatory investigations take time. Track 2 investigations – only reserved for the most serious cases – can take a minimum of 3 months to complete and some longer. Requesting information, assessing large amounts of data, considering the evidence, giving time to providers to respond to enquiries and compiling cases is often complex and requires meticulous attention to detail. Of course, we aim to avoid any undue delay in processing cases and we will continue to examine any efficiencies that can be achieved.

You perceived there to be room for improvement on demonstrating our understanding of the bigger picture and articulating our longer-term strategic vision. We launched a set of new vision, mission and strategic priorities in November and these will take time to bed in. These drive everything we do.

Overall, the findings were broadly positive and consistent with the feedback we receive from you on a one-to-one basis. This means that we are already looking to address much of your feedback and concerns through our annual business plan. That’s not to say we aren’t doing anything as a direct result of your feedback.

Indeed, we’ve identified 5 areas where we are going to focus on in response. These are:

Strategy – as I mentioned, we have a new vision, mission and strategic priorities. We will look to give these more prominence so that stakeholders have clarity about what these are and can see how we are delivering against them. We are also looking to flesh out what we mean by a healthy and innovative market. This is to give stakeholders a sense of how we will look to support competition, growth and innovation in the consumer interest.

Industry engagement. A number of you commented on how open and engaged we are. We want to continue to roll out our industry engagement programme to major Level 2s that we may not engage with on a regular basis.

Regulatory complexity. Some of you told us that complexity was an issue for you. We want your regulatory obligations to be clear; compliance shouldn’t be a challenge. We are exploring whether there would be appetite for regular compliance workshops – a number of you have already expressed an interest in attending an event on aspects of our revised supporting procedures. We also recently launched a six month pilot to help Level 1 providers attract merchants to operator billing, which you can find out more about here.

Consumer awareness. As part of Project 30, we developed a new consumer strategy, which is currently being implemented. One of the key deliverables is a new website with clear consumer information, so that consumers can self-help in the first instance.

Speed. We are looking at increasing automation of our processes to ensure we are as efficient and effective as possible. We have recently upgraded our Customer Relationship Managament (CRM) system, which should give us greater functionality and better analytics. We will continue to explore how we can improve our responsiveness without jeopardising quality.

Again, thanks to all of you who took part in the research. We do value your feedback. Please don’t hesitate to be in touch if you have any questions about the findings.

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